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HomeMy WebLinkAbout04-2956 Complaint--Custody, Partial Custody, Visitation~ COMPLAINT FOR e b~Fc~ ~ ( CUSTODY ) (PARTIAL CUSTODY ) (VISITATION) 1. The plaintiff is ~II~'~Vc, residing at"l,~ Co~ I~-o~ '~. C,~< ~*~,,¢~ 2. ~e defend~t ~mvk~?~g~siding at~O~ ~-~ q ~' ~' 3. Pl~nfiff seeks Cn s+~ ~ (c~tody) Cartial custody) (visitation) of the following child(ten): Nme ~esent Residence Age The child l,.~tS (was) (was not) born out of wedlock. The child is presently in the custody o~ (name) who resides at 1~ ~a~?¢~(Street, City, State). M r~ v ~ ~-. ~ ~*¢ During the past five years, the child has resided with the following persons and at the following addresses: List All Persons List All Addresses Dates ~ ~e moor of ~e child is[Gl 1 ~s fora is mqukcd by Pa. R. Civ. P. 1915.15(a), ~d fora of complaint is appropriate where ~ere is one plaintiff cust~y of one c~ld is sought, or where ~c cust~y of sever~ c~l~n is sou~t ~d ~e infomafion requk~ by pm~aphs 3 to 7 is iden~c~ for ~1 of ~c chil~n. ~em there ~ multiple p~ies, · e compl~nt should ~ appropriately adap~d to acco~a~ ~*m. ~e~ ~c cust~y of sever~ chil~en is sought ~d ~e infomafion ~quired is no~ idenfic~ for all, ~e compl&nt should contain a sep~atc p~a~aph for each child. As in ~1 ~as of domestic relations practice, custody procedures may v~y ~om coun~ m county and ~c practitioner should ~ways review ~e applicable county's roles to ins~e hll compli~ce. KELLY Y. PHARR-MOSES PLAINTIFF TRAVIS A. FLEMING, SR. DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 04-2956 CIVIL ^ CTION LAW : : 1N CUSTODY ORDER OF COURT AND NOW, Wednesday, June 30, 2004 _, upon consideration of the attached Complaint, it is hereby directed that parties and their respective cotmsel appear betbre Dawn S. Sunday, Esq. , the conciliator, at 39 West Main Street, Meehaniesburg, PA 17055 on Tuesday, August 03, 2004 at 10:00 AM for a Pre-Hearing Custody Conference. At such conference, m~ eflbrt will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. All children age five or older may also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. The court hereby directs the parties to furnish any and all existing; Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR 7'HE COURT, By: /s/ Dawn S. Sunday, Esq. Custody Conciliator The Court of Common Pleas of Cumberland County ~s required by aw to comply with the Americans with Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business betbre the court. You must attend the scheduled conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATFORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE I'HE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 KELLY Y. PHARR-MOSES Plaintiff VS. TRAVIS A. FLEMING, SR. Defendant IN THE COURT OF COMMON PLEAS OF CUMBERL.~aND COUNTY, PENNSYLVANIA 04-2956 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, this [/~ ~ day of _, 2004, upon consideration of the attached Custody Conciliation Report, ordered and directed as follows: 1. The Father shall have primary physical custody of Trams A. Fleming, Jr., bom March 10, 1993, until such time as the Mother provides documentation that all results of drug testing conducted pursuant to the terms of the Mother's parole have been negative to the Father prior to the beginning of the 2004-2005 school year in the school district in which the Father resides. 2. Upon providing the foregoing information prior to the beginning of the 2004-2005 school year to the Father, primary physical custody of the Child shall be transferred to the Mother and the Father shall be entitled to have periods of partial physical custody with the Child as arranged by agreement between the parties. 3. The Mother shall be responsible to provide transportation for the Child between the Father's residence in Virginia and the Mother's residence in Pennsylvania for the transfer of primary custody. 4. In the event the Mother does not provide the documentation to the Father required by this Order prior to the beginning of the 2004-2005 school year in Virginia, the Father shall retain primary physical custody of the Child and either party may contact the conciliator to request the scheduling of further proceedings. 5. This Order is entered pursuant to an agreement of the parties at a custody conciliation conference. The parties may modify the provisions of this Order hy mutual consent. In the absence of mutual consent, the terms of this Order shall control. BY TH~T,~ Edward E. Guido cc: ~ Y. Pharr-Moses, Mother t~avis A. Fleming, Sr., Father KELLY Y. PHARR-MOSES Plaintiff VS. TRAVIS A. FLEMING, SR. Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 04-2956 CIVIL ACTION LAW IN CUSTODY Prior Judge: Edward E. Guido CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Child who is the subject of this litigation is as follows: NAME Travis A. Fleming, Jr. DATE OF BIRTH CURRENTLY IN CUSTODY OF March 10, 1993 Father 2. A conciliation conference was held on August 3, 2004, with the following individuals in attendance: The Mother, Kelly Y. Pharr-Moses, who is not represented by counsel in this matter. The Father, Travis A. Fleming, Sr., who resides in Virginia and is also not represented by counsel, participated in the conference by telephone. 3. This Court previously entered an Order in related dependency proceedings concerning this Child on December 23, 2003, under which the Child was removed from the Mother's residence and placed in the Father's care. The Mother filed this petition for custody seeking to have the Child returned to her primary care. 4. The pa~'les agreed to entry of an Order in the form as attached. Date Dawn S. Sunday, Esquir~c~ Custody Conciliator